Because of the borderless nature of the Internet, you understand and agree to comply with all local regulations regarding online conduct and acceptable “User Contents”. In particular, you agree to comply with all relevant laws regarding the export of technical or personal data from the country or region in which you reside.
You understand and agree to be responsible for all your actions in using the Services and agree to indemnify and hold the Company harmless for such actions. You also agree to indemnify and hold the Company and our partners harmless from any claim or demand by any third party arising out of or related to your use of the Services, User Contents provided or posted or transmitted by you through the Services, your violation of the Terms, or your violation of the rights of others, and to assist in resolving disputes.
You agree not to reproduce, resell, or use any part of the Services for any commercial purpose or the use of or access to the Services.
The Company reserves the right to establish general measures and restrictions relating to the Services, including, but not limited to, the maximum period for which the Services will retain SMS messages, bulletin board contents or other uploaded “Contents”, the maximum number of SMS messages that can be sent or received within an account on the Services, and the maximum number of times you may use the Services (and the maximum duration of each use) during a specific period in general. You agree that the Company will not be liable for the deletion or failure to store any messages and other communications and other “Contents” that we maintain or transmit on the Services. You also agree that if you do not activate your account for more than 365 days, we have the right to terminate that account and the related rights.
The Company may modify or terminate the Services (or any part thereof) temporarily or permanently at any time. You agree that we shall not be liable to you or any third party for any modification, suspension or termination of the Services.
The Company may suspend or terminate your member account for any reason, including, but not limited to, prolonged non-use, breach of the Terms, etc. You understand and agree that if your use of the Services is terminated, the Company may delete your relevant data and shall not be liable to you or any third party.
The Company may provide advertising content with collaborative vendors provided by advertisers, product or service providers. You understand and agree that you should judge the suitability and truthfulness of the advertising contents at your own discretion and that the Company is not responsible for the contents of the advertising.
Your communications or commercial dealings with advertisers on or through the Services, or participation in promotions, including payment and delivery of related goods or services, and any other Terms, conditions, warranties or representations associated with the foregoing transactions, are solely between you and the foregoing advertisers. The Company will not be liable for any loss or damage of any nature incurred as a result of any foregoing transactions or the presence of the foregoing advertiser on the Services.
The Services may provide links to websites or resources provided by other third parties, the contents of which are the sole responsibility of the respective operators and are not under the management of the Services. Because the Company has no control over the foregoing websites or resources, we cannot guarantee the quality, accuracy or legality of the contents provided on the foregoing websites or resources. You understand and agree that you should exercise your own discretion in determining whether to make use of the foregoing external websites or resources and that the Company is not responsible for third party links. You further agree that the Company shall not be liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any “Contents”, goods or services available on or through any websites or resources mentioned earlier.
You understand and agree that the Company shall not be liable for any direct, indirect, incidental, special, derived or punitive compensations, including but not limited to damages for loss of profits, goodwill, use, data loss or other intangible losses, arising out of:
The Company respects intellectual property rights. If you believe that your work has been reproduced in a way that constitutes copyright infringement, please provide us with the following information:
You acknowledge and agree that you have right to delete the user account upon access to the Service, provided that you shall comply with the steps and policies on deletion of the account related to the Service and App.
Upon your acknowledgement of an agreement to the circumstances arising upon deletion of the account, including but not limited to, prohibition of the re-application for the same account within specific time limit, a period of time and technical processing are needed by the Company subsequently, and the Company’s retention of certain data for legal purposes within specific time limit, you may click the option for deletion of account via the App or file an application for deletion of the account with the Company. The Company will proceed to confirm and process your application accordingly.
You acknowledge and agree that, in consideration of the specific rewarding activity and interactive functions provided by the Service, upon your application for deletion of the account, the Company shall process your personal data in accordance with the Personal Data Protection Act and related App policies, provided that the Company reserves the right to retain the following data in connection with the specific rewarding activities or interactive functions pursuant to laws and for legal purposes:
The Policy applies to all MPA respondents who agree to participate in the marketing research program (hereinafter referred to as "Program"), which includes downloading and installing RealityMine developed software applications (hereinafter referred to as "Applications") on their mobile devices or computers.
Primary contact: The Data Controller MPA
Full name of the legal entity: Media Partners Asia Research Services Pte. Ltd.
Name or Title: The Data Protection Officer
Mail address: 45A Amoy Street, Singapore 068971
Additional contact: The Data Processor, RealityMine
Full name of the legal entity: RealityMine Ltd.
Name or Title: Data Protection Manager
Mailing address and recipient: Data Protection Manager, RealityMine Limited.Warren Bruce Court, Warren Bruce Rd, Stretford, Manchester, M17 1LB, United Kingdom
Additional contact: The Data Processor, EK2A
Full name of the legal entity: EASY KEY 2 ASIA LIMITED
Name or Title: Data Protection Manager
Contact address and recipient: 5F-1, No. 88 Yanchang Road, Xinyi District, Taipei City
Additional contact: The Data Processor, Ad2iction -
Full name of the legal entity: Ad2iction LIMITED
Name or Title: Data Protection Manager
Contact address and recipient: 7F, No. 367, Fuxing North Road, Songshan District, Taipei City
You have the right to contact the relevant regulatory agencies at any time. Still, we hope that you could contact us before contacting the regulatory agencies in order for us to assist you in matters of your concerns and worries about the usage of your data. Therefore, we would be very grateful if you could contact us in the first instance.
The accuracy and timeliness of the personal data we hold about you are very important. Please notify us immediately of any changes to your personal data during the period of cooperation between you and us.
Information we hold:
We may collect and hold personal and non-personal information about you as described below.
Personal data or personal information refers to any personal-related data from which an identity can be named but does not include data from which the identity has been removed (anonymous data).
We collect, use, store and transmit a variety of your personal data and categorize it as follows:
We do not collect any special types of personal data about you
(including details on your race, religious and philosophical
beliefs, sex life, sexual orientation, political views, union
membership, and health, genetic and biometric data). We also do
not collect any data about criminal convictions and violations.
The way we collect information:
We use different methods to collect data about you. The following details of how to use the Applications to collect data.
The Applications collect "clickstream data" and collect diary/survey data after they have been set up. Clickstream data is the information that you and your Device generate as you browse the Internet and interact with a variety of websites, services and device features.
This service will install the "Dashboard". The “Dashboard” is the software that collects the data mentioned above from your device. We will only use the data described in the Policy.
The following types of information are collected by the Applications:
The above list covers examples of the types of data collected, but is not a complete list of all individual data elements.
We have taken appropriate security measures to protect your
personal data from accidental loss, theft, or unauthorized
access, alteration, or disclosure. In addition, only employees,
agents, contractors and other third-party collaborative vendors
with business needs will have access to your personal data. The
aforementioned parties will process your personal data only in
accordance with the instructions of the Data Controller and will
assume responsibility and liability for confidentiality.
We have developed ways to respond to any suspected leakage of personal data and are required by law to notify you and any applicable regulatory agencies of such violations.
We may use the technology called "cookies" to collect certain
information. A cookie is a small text file that is stored on
your device through the browser. If you return to the site using
the same device and browser, the site can recognize you through
the cookie and store your preferences and other information.
We use a temporary work-stage cookie during the download and registration process to correctly identify the marketing research team you have joined, add a unique anonymous identifier, and trigger the download process.
We will only use your personal data under lawful conditions. In general, we will use your personal data in the following circumstances:
We process your data according to our legitimate interests and ensure that our contract with the Data Controller is fulfilled.
This chapter describes how your data (including web usage, application usage, demographic statistics, survey responses, and information we obtain from third party collaborative vendors) will contribute to the services provided by the Data Controller to its individual or multiple customers (hereinafter referred to as “Customers”). Generally speaking, the team members’ data will be merged into the consumer segment data and reported in an aggregate or categorized manner. A consumer segment is a group of users who share common interests or characteristics, such as “women aged 28-34 who want to use Netflix”. Once data is aggregated, the aggregated results and consumer segments are shared with the Customers of the Data Controller and other parties described in this Policy. In some cases, the Data Controller may share unaggregated results for restricted purposes. The following are examples of the types of services offered by the Data Controller and the ways in which your data may be used in these services:
Advertising marketing - Your data is merged with other users' data into a customer data pool for analyzing the exposure of specific advertisements. The information in the merged data pool will not identify any specific users. It will be shared with the Data Controller for capturing and understanding how and to what extent advertising spending influences consumer journeys and decision making. For example, comparing the behavior of two user groups, one that has seen a specific online ad and the other that has not.
Media usage analysis - Your data is merged with other users’ data to form a consumer segment that is shared with the Data Controller without any specific user information being identified in the data. We typically analyze these consumer segments on behalf of our Customers to understand where consumers are surfing the Internet and how they are interacting with digital media, including the website contents, applications, and advertisements they are viewing. For example, the Data Controller can help companies understand how effective their websites or applications are by comparing how users interact on their own websites or applications to those of their competitors.
Creating a personal file - The Data Controller may obtain additional information about you from other public or private data sources, using personally identifiable information that you provide to us outside of the Applications, or using anonymous identifiers associated with you (such as IP addresses or similar identifiers). The data sources of these third-party collaborative vendors may provide the Data Controller with information about your online and offline purchases, information about your family and lifestyle, as well as broader demographic and personal history breakdowns. The Data Controller can merge this information with other information to add and improve the shared personal files described in this Policy. For example, by looking at web browsing activities and in-store purchase behaviors, the Data Controller's marketing research can determine whether members of a particular consumer segment visit particular websites in the course of researching a product (such as a television, computer, or automobile), but are more likely to visit a brick-and-mortar store. Such data helps the manufacturer or distributor of the products to better understand where to find Customers interested in their products.
Consumer analytics - The data controller uses your data, either personally, identifiable information obtained directly by the Data Controller or through trusted third-party collaborative partners, to optimize and improve the consumer base on the Data Controller or its Customers. When Customers already have such information, the Data Controller uses personally identifiable information in this manner because it is often the only way to match the personal files held with the Customers’ personal files. Sometimes the Data Controller will collect information from your clickstream data, such as work-stage ID, and share that information with third-party collaborative vendors in order to match your information with information held by the third-party collaborative vendors as part of their services. While in these cases, the Data Controller will allow third parties and their Customers to use your information to enhance the overall consumer base and for advertising purposes, in the general course of your online activities, you will be a member of a broader consumer base and therefore will see specific advertisements created with the help of your data.
Targeted surveys - Based on the data collected by the Applications, the Data Controller may send you invitations to participate in surveys based on your online activities. For example, if you visit a website that indicates that you enjoy traveling, the Data Controller may send you a survey about travel services. The Data Controller may provide some or all of the survey responses to its Customers, but will not provide information in the responses that can directly identify any particular user, including specific responses and quotes from individual respondents.
The Data Controller may also use your information for the
following purposes: To maintain the settings and proper
functioning of the Applications, database or application
services (such as customer support, email or surveys), and data
quality maintenance and data cleanup.
The Data Controller will collect information such as your name, telephone number, email address, year of birth, family information, income and gender directly from you during the registration process prior to the installation of the Applications or during participation in a survey or other services. Such kind of information is part of your consumer personal file and will be used as described above. The Data Controller will also contact you via the contact information you have left to provide information about application maintenance and updates as well as other service-related communication. In addition, for research purposes, our ShareParty research team may conduct in-depth interviews by telephone in the future. By joining the program and providing your contact phone number in the survey response, you consent to be interviewed by phone.
When working with a third party collaborative vendor (such as a
third party data provider) to supplement your personal file, to
protect your privacy, the Data Controller will ask the data
provider to sign a confidentiality agreement stating that
personally identifiable information will not be shared with
unauthorized parties. The Data Controller will give explicit
instructions to the data provider to maintain the
confidentiality, security and integrity of the information we
provide and not to use the information for purposes other than
those expressly authorized.
The Data Controller will share your information with authorized vendors and service providers in connection with the services they perform and prohibits third party collaborative vendors from using your information for other purposes.
If we undergo a business transformation, such as a merger,
acquisition, or sale of all or part of our assets, your
information will be part of the transferred assets.
We also reserve the right to disclose your information when we believe disclosure is necessary to protect our rights or to combat suspected fraudulent activities, in accordance with the laws, a court order, or a proceeding required legally.
You may opt out of this survey program at any time by removing the Application from your Device. For instructions on removing the Applications, please read the instructions provided to you when you first join the survey and follow all of the detailed steps for removing the Application. However, the procedure for individual operating systems is outlined below:
If you are unable to exit the data collection program in a quick and easy way, please let us know and we can assist you with the request. If you have any questions about removing the Application or exiting the program, please be sure to contact the Data Controller.
If you have set your browser to "private browsing" or similar settings, the Application will continue to run, collect data, and send it to us. To completely stop the Application from running and stop collecting data from your Device, you must follow the steps described above to remove the Application.
We have taken appropriate technical and organizational measures
to protect your personal data from accidental loss, theft, or
unauthorized access, alteration, or disclosure. In addition,
only employees, agents, contractors and other third-party
collaborative vendors with business needs will have access to
your personal data. The aforementioned parties will process your
personal data only in accordance with our instructions and will
assume responsibility and liability for confidentiality.
We have developed ways to respond to any suspected leakage of personal data and are required by law to notify you and any applicable regulatory agencies of such violations.
If we become aware of an information security breach that may
result in the destruction, loss, alteration, unauthorized
disclosure of, or access to, customer data or personal data
(each, an "information security incident"), we will, without
delay, immediately (1) notify the Data Controller of the
information security incident; and (2) work with the Data
Controller to take reasonable steps to mitigate the impact of
the information security incident and reduce potential losses.
Notice of information security incidents will be sent to the data subject by the Data Controller.
In this chapter, our describing our obligations to report or respond to an information security incident does not mean that we acknowledge our negligence or liability related to information security incidents.
The Data Controller must promptly notify us of any potential data misuse.
You have the right to make requests to:
If you would like to review your personal data held by us,
please approach the contact window for a Data Subject Access
Request (DSAR) form, which will be provided to you within 30
business days. You will be asked to submit two types of
identified certificates dated within the last three months to
the Data Controller for the DSAR.
If you wish to file a complaint, you can approach the contact window, which will respond within 30 days.
Legitimate interest means that we have a business interest in
operating and managing our business in a way that provides you
with the best possible services/products and the best possible
security experience. Before processing your personal data for
our legitimate interests, we will ensure that we consider
carefully and determine any potential positive or negative
impacts on you and your rights. We will not use your personal
data for activities that affect you more than our interests
(unless we have your consent or are otherwise required or
permitted by laws). You can contact us for further information
about how we assess our legitimate interests to avoid potential
impacts on you in particular activities.
Performance of a contract refers to measures taken to perform a contract to which you are one of the contracting parties or respond to your request before the contract is concluded, so that your data will be processed as needed.
Compliance with laws or regulatory obligations means processing your data as necessary to comply with laws or to meet our regulatory obligations.
You have the following rights:
To request access to your personal data (commonly referred to as a "data subject’s access request"). This request allows you to obtain a copy of the personal data we hold about you and check whether we process such data according to the laws.
To request correction of the personal data we hold about you. Although we will need to check the accuracy of the new data you provide, this request allows you to correct incomplete or incorrect data that we have about you.
To request deletion of your personal data. You may request that we delete or remove personal data when we have no legitimate reason to continue processing your personal data. You also have the right to request that we delete or remove your personal data after you have successfully exercised your right to object to the processing (see "Objection to data processing" below for details). For example, if we process your personal data illegally, or if we are required to delete your personal data to comply with local laws and regulations. Please note, however, that we may not be able to complete your data deletion request for specific legal reasons, and we will notify you if there is an applicable legal reason when you make such a request. Your request will be processed within 90 days in accordance with our company policy.
Objection to data processing means objecting to our processing of your personal data based on our legitimate interests or those of a third party, as well as in special circumstances relating to you, where you believe that the data processing would affect your fundamental rights and freedoms so you object to it from this position. You also have the right to object to our processing of your personal data for the purposes of direct marketing. In some cases, we will demonstrate that we have a compelling legitimate position to process your data that overrides your rights and freedoms.
To request restrictions on the processing of your personal data. Under the following circumstances, you may ask us to suspend the processing of your personal data: (a) if you want us to confirm the accuracy of the data; (b) if we are using the data unlawfully but you do not want us to delete it; (c) if you need us to continue to hold the data even though we no longer need it in order to establish, exercise or defend a legal claim; or (d) if you have objected to our use of your data, but we need to check whether there is an overriding legitimate reason for continuing to use the data. At the direction of the Data Controller, we will carry out data processing operations to produce our data package products. Your Data Controller will receive selected reports to meet their business needs.
To request the transmission of your personal data to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format to you or a third party collaborative vendor of your choice. Please note that this right applies only to automated information that you initially provided and consented to our use, or information that we use to fulfill our contract with you.
To withdraw the consent on which we rely to process your personal data at any time. However, this will not affect the legality of the data processing we undertake prior to your withdrawing your consent. If you withdraw your consent, we will not be able to provide you with certain products or services. We will inform you if there are any of the above circumstances when you withdraw your consent.
Under the following circumstances, we will retain the information described above for up to three years from the initial date of data collection for as long as the information remains valuable to us in providing services to our customers or is necessary to comply with legal obligations, resolve disputes, and fulfill agreements. If you opt out of the survey program and follow the instructions in the Remove the Applications chapter, we will no longer collect data from you, but we will continue to use the data collected prior to the removal of the Applications unless you contact us in accordance with the data access rights chapter.
We do not collect personal information from users under the age of 15 for use by the online research team. If we do attempt to collect personal information from users under the age of 15 in the future, we will obtain verifiable parental consent, where applicable, and comply with the “Children's Online Privacy Protection Act” and all applicable data protection laws.
If we hold any personally identifiable information about you,
you may contact the Data Controller to request for your contact
information to be corrected, updated, or deleted.
If you have questions about this Policy, the data collected by the Applications, or have other privacy-related concerns, please contact the Data Controller.
To contact the DPO of the Data Controller's, please send a message to email@example.com
To contact the DPM of the Data Processor, RealityMine, please send a message to firstname.lastname@example.org
To contact the DPM of the Data Processor, EK2A, please send a message to email@example.com
To contact the DPM of the Data Processor, Ad2iction - ShareParty, please send a message to firstname.lastname@example.org
The Terms constitute a legally binding agreement between you, as a user of the App, and MPA. By downloading, installing and using the App, you acknowledge that you have fully read, understood and agreed to all of the Terms and all other applicable regulations. If you do not fully agree to all of the Terms, you must uninstall the App from your mobile, portable or desktop device (hereinafter referred to as "Device").
We hereby grant you a personal, non-exclusive, non-transferable,
limited authorization to download the App for your limited,
private, non-commercial, and lawful use on your Device, subject
to and in accordance with the Terms. MPA owns all copyrights,
trademarks, other intellectual property rights, and proprietary
rights to the contents of the App or any software, images, or
design used in connection with the App. Except as provided in
the Terms, you agree not to reproduce, distribute externally, or
modify any part of the App or derivative products without MPA's
prior written consent. MPA reserves all rights not granted here
in the Terms.
You declare and guarantee that you have the right to install and use the App on the Device on which it is installed.
Both parties may terminate the authorization at any time. We may deactivate the App on your Device immediately, with or without providing notice.
You can deactivate the App at any time by following the exit options and App removal instructions below:
The App will then stop collecting and transmitting information
about you. Please note that in accordance with our Privacy
Policy, we will continue to use the information collected and
sent to us before you discontinue using the App. Upon
termination of your authorization, you should immediately stop
using the App and remove all or partial copies of the App, other
specific forms of the App, and confidential MPA information in
your possession or control.
If you fail to comply with any of the Terms, we may (without prejudice to any other rights we may have) suspend or immediately terminate your access to the App or other applicable account or service.
You agree to indemnify and hold MPA, its officers, employees, business partners and agents harmless from and against any claims, damages, obligations, losses, liabilities, costs or debts, and expenses (including but not limited to attorneys' fees) arising out of (i) any breach by you of the Terms or (ii) any breach by you of applicable laws or any agreements or provisions between you and a third party.
Please note that your Device must meet our minimum standard technical specifications and compatibility notices in order to use the App. We recommend checking the specifications first to ensure that your computer or portable device is compatible with the App. We are not responsible for any failure due to incompatibility with the App (including but not limited to the minimum storage capacity and memory requirements that may occasionally be required).
The App and all contents, features and characteristics covered
by the App (hereinafter referred to as "Materials") are provided
"as is" without warranty or declaration of any kind, either
express or implied. To the maximum extent permitted by laws, MPA
does not guarantee satisfactory quality and fitness for a
particular purpose or that the contents and information
displayed on the App are accurate, complete, current, or does
not infringe upon the rights of any third party. MPA does not
guarantee that the features contained in the Materials will be
uninterrupted or error-free. Except as otherwise expressly
provided in the Terms, and to the extent permitted by laws, we
make no other declarations, guarantees or recourses, express or
implied. We hereby exclude all other terms, declarations and
guarantees that may be implied from the contents of the Terms.
We will make reasonable efforts to ensure that the App is free of viruses or other malicious contents, but neither we nor any third parties involved in the creation of the App will be liable. We will not be liable for any damage caused by destruction to, or viruses that may infect, your computer equipment or other property that you use for access, the App or any material, data, text, image, video or audio that you download from the App. Except as otherwise required by laws, MPA shall not be liable for any loss or damage caused by viruses or other malicious and harmful contents that may be accessed by or through the App.
Any information, data, reports, analyses and results (hereinafter referred to as "Data") generated after the App is installed on your Device are the property of MPA. We have no obligation to use, collect, or analyze any Data about you.
We reserve the right to modify the Terms or the features,
characteristics, and contents of the App at any time. We may
automatically update the App on your Device. Changes to the
Terms will be posted on our website or otherwise notified to
you. Please be sure to visit our website regularly. If you wish
to take advantage of the changes, you may need to download a new
version of the App.
Articles 7 and 8 are subject to change by the customer in accordance with local jurisdiction.
The Terms apply only between you and MPA and may not be enforced by any third party other than MPA's partners.
The Terms apply to the laws of England and Wales and any cause
of action or dispute arising out of or in connection with the
Terms shall be exclusively under the jurisdiction of the courts
of England and Wales.
You are responsible for compliance with applicable local laws relating to the use of, or in connection with, the App. For example, if the App or the activities contemplated by the App would in any way violate any laws outside the jurisdiction of England or attempt any illegal activity, you will be prohibited from accessing or using the App, and this will override all other provisions of the Terms.
Users with any questions should contact the ShareParty team, an MPA partner, for further inquiries.